Sullivan was hired in January 2005 and let go March 2011. When Lee was on tour, including as a DJ, Sullivan claims he had 16-hour days without breaks or overtime compensation. He once was asked to live at Lee’s house but, after a while, claims Lee deducted $1,000 a month from Sullivan’s paycheck for rent – including the last six months of employment when Sullivan was not living there.

Lee is also accused of creative accounting tactics like deducting cell-phone charges from Sullivan’s pay when the latter was making calls on Lee’s behalf. Sullivan also claims, because Lee talked disparagingly of him after the termination, he lost two potential jobs as tour manager for Godsmack and Bush.

Sullivan seeks “no less than $50,000” for OT pay plus punitive damages “in an amount sufficient to punish Lee and make an example of him.”